Privacy Policy

Surrogate Fund Management, LLC (the “Company”) is extremely committed in our efforts to maintain the privacy of individuals. The purpose of this Privacy Notice is to make you aware of what information we collect, what is deemed non-identifying information, how that differs from identifying information and how we use this information.

The Company manages escrow accounts for individuals and entities in connection with reproductive arrangements. In our efforts to best serve the needs of our clients, we may obtain personal information which includes both non-identifying and identifying information from all parties. This information may be obtained via the internet, mail or telephonically.

By using our website, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, you should not use our website. Your continued use of our website following the posting of changes to this Privacy Policy will mean that you accept those changes.

Privacy of Minors

This website is not intended or designed to attract users under the age of 18. SFM does not collect personally identifiable data (“Personal Information”) from any person we know to be under the age of 18, and we instruct users under 18 not to send us any information.

Information We Collect

SFM collects information on our website in essentially two ways.

(1) Automatic Data Collection

When you use our website, we may collect “Non-Personal Information,” which is information that, by itself, cannot be used to identify or contact you, such as demographic information (your age, gender, income, education, profession, ZIP code, etc.). Non-Personal Information may also include technical information, such as your IP address, the type of browser you are using, the websites you visit immediately before and immediately after you visit our website, and other anonymous data involving your use of our website. Non-Personal Information may also include information that you provide us through your use of our website, such as the terms you enter into the search functions of our website.

(2) Data Disclosed By You

At various locations on our website, such as in registration forms, profiles, surveys, discussion forums and polls, SFM may request that you supply us with personal information, such as your name, email address, mailing and shipping addresses, home or work telephone number, your health and family health and employment. Although you do not have to provide us with any information to visit our website, you may not be able to fully utilize all of the services on our website if you choose not to provide certain information. If you do choose to give us personal information through our website, we will collect and retain that information.

Cookies

SFM may place a text file called a “cookie” in the browser files of your computer. “Cookies” are small amounts of data that a website can send to your browser and store on your computer. Cookies do not contain personal information about you (unless you knowingly provide it). Cookies can note that your browser was used to visit certain websites, pages, or advertisements on a certain date. SFM uses cookies to enhance the navigation and the functionality of our website, to verify your identity, and to personalize aspects of your experience on our site. For example, if you are a registered user of our site, when you login, a cookie will be placed on your computer’s hard drive in order to maintain your session while you are using our website.

You do not need to accept cookies in order to access and use our website. Although the default setting for most web browsers is to accept cookies, most browsers can be set to notify you when a cookie is being placed on your computer, or to reject all cookies. However, if you do not accept cookies, this may affect your Internet experience. For example, on our website, you may not be able to maintain your login. You can erase cookies that are already on your computer. For more information on working with cookies, consult the Help function of your specific browser and operating system software.

How We Use the Information We Collect

(1) Services and Website

We use your Personal Information to provide you with any services that you may request or require, to communicate with you, and to allow you to participate in our online applications. We use aggregated Non-Personal Information about our users to understand our website’s demographics, such as the percentage of male and female users, the geographic distribution of our users, the age ranges of our users, or a combination of these or other demographics. We use the Non-Personal Information we collect to analyze how our website is being used, and to improve the content of our website, online services, and marketing and promotional efforts.

(2) Email Communications

If you send us an email with questions or comments, we may use your Personal Information to respond to your questions or comments, and we may save your questions or comments for future reference. We may send you emails to communicate with you about your account and to provide customer support in connection with the services we are providing for you.

Non-Identifying Information

Non-identifying information can be defined as information which can not be utilized to identify a particular individual, such as age, race, ethnicity, height, weight, etc. Non-identifying information may be released to: i) internally for auditing purposes, demographic research and the like; or ii) for any lawful purpose. No personal or identifying information which could specifically identify an individual will be released in this regard.

Identifying Information

Identifying information can be defined as any information which can identify a specific individual such as a name, social security number, address, telephone number, etc. SFM will be acquiring identifying information from individuals as necessary to complete its work. Identifying information will not be released by SFM to the public except as noted below:

As Required by Law. SFM may use and disclose your identifying information when required to do so by law. This includes, but is not limited to, a response to any judicial order, subpoena, summons, warrant, discovery request, or similar legal request and/or administrative proceedings; in reply to a request from law enforcement for information; in order to warn law enforcement of any criminal actions on the premises of SFM or of any fatality which may result from said criminal actions. In addition, identifying information may be disclosed to comply with government mandated reporting.

Coordination of Health Care. SFM may use and disclose your identifying information in order to coordinate medical related activities between your primary physician, any consultants and any and all other medical personnel who may need such identifying information in order to ensure your proper care and treatment in addition to any legal obligations.

Public Safety. SFM may use or disclose your identifying information if we deem that it is reasonable to conclude that said disclosure is required to either mitigate or prevent an impending risk to the health and/or safety of an individual or the community. SFM may use and/or disclose your identifying information, as required, in order to support the day to day business activities and management of SFM. Said activities include, but are not limited to, assessment of quality of service, auditing and/or accounting support, licensing, information technology systems, and legal support.

Business Associates. Some services provided by SFM require the use of third party service providers. SFM may reveal your identifying information to said service providers only as required in order to perform the service for which they have been contracted and as permissible by law. We require any and all business associates to diligently safeguard the privacy of your identifying information.

Marketing. SFM may contact you in regard to new technologies, services and/or alternative treatments that SFM believes may be of use to you.

Other. SFM reserves the right to use and disclose your identifying information for any and all purposes as permitted under the law.

Because of the ever changing technology and advances in computer technology and the internet, SFM can not guarantee that identifying information will not be released without our knowledge. However, SFM will use every reasonable effort to ensure that your identifying information remains private and secure.

All non-identifying information and identifying information is obtained by SFM voluntarily from recipients, donors, gestational carriers and intended parents. SFM makes no representations or warranties as to the accuracy of the information which is not a work product of SFM.

Internet Disclaimer

SFM’s website may contain links to other websites for the convenience of our clients to navigate the internet and view related sites. SFM is not responsible for the content or reliability of any or all of the information, services or practices of these websites. SFM is not responsible for the privacy policies, or lack thereof, of any linked websites.

Contact Us

If at any time you believe that SFM has not adhered to the principles outlined in this Privacy Policy, please notify us by email and we will use all commercially reasonable efforts to promptly determine and correct the problem.